IEEPA Tariff Refund — Frequently Asked Questions

Who qualifies for an IEEPA tariff refund?

Three distinct groups of U.S. businesses may be eligible:

• Tier 1 — Direct Importers (Importer of Record): businesses listed on CBP Form 7501 (Box 26) who paid IEEPA duties under HTSUS lines 9903.01 or 9903.02 between February 1, 2025 and February 23, 2026. Typical fit: $3M+ in annual imports, or $1.5M+ if China-heavy.
• Tier 2 — Courier-imported businesses: companies whose goods came in via FedEx, UPS, or DHL where the courier appears as Importer of Record. The IEEPA dollars still belong to your business; they're claimed via the courier. (Same volume thresholds as Tier 1.)
• Tier 3 — Pass-through buyers (largest opportunity): companies who bought from U.S.-based suppliers that imported and passed the IEEPA tariff cost down — either as an invoice line item or as a 2025 price increase. Typical fit: $1.5M+ in annual spend with importing suppliers. Approximately 1 million additional U.S. businesses are estimated affected through this path.

Most qualifying clients across all three tiers have $300,000+ in recoverable IEEPA exposure. Fringe cases starting at $150,000 are evaluated. Below $150,000, the contingency math rarely works.

Can my business recover IEEPA tariff money if we weren't the Importer of Record?

Yes — in two distinct scenarios:

Tier 2 (Courier import): If your goods arrived via FedEx, UPS, or DHL and the courier was the Importer of Record on customs filings, your business still absorbed the IEEPA cost via carrier surcharges or invoice line items. The partner firm files a claim through the courier on your behalf. The framework is still developing but cases are being actively built.

Tier 3 (Pass-through buyer): If your business bought goods from U.S.-based suppliers, distributors, or manufacturers who imported them and passed the IEEPA tariff cost to your business through invoicing or 2025 price increases, the partner firm pursues a legal demand on the supplier on your behalf — while preserving the underlying commercial relationship where possible.

The Tier 3 pool — approximately 1 million additional U.S. businesses beyond the ~330,000 direct importers — is the largest single recovery opportunity opened by the ruling, and the one most refund firms in market today aren't pursuing.

How do I know if I'm a Tier 3 pass-through buyer with a claim?

Two signals to check for:

1. Invoice line items. Pull 2025 invoices from your U.S.-based suppliers and look for explicit line items labeled "tariff," "IEEPA surcharge," "duty pass-through," "import surcharge," or similar. Many suppliers itemized the tariff cost rather than absorbing it.
2. Unexplained mid-2025 price increases. If no line item is visible, watch for sudden 5-25% price hikes from importing suppliers in the April-September 2025 window, especially on China-origin goods. Some suppliers buried the tariff inside a price increase rather than itemizing it to mask the pass-through.

If your business spends $1.5M+ annually with U.S. suppliers who import, and either signal is present, your business likely has a Tier 3 claim worth pursuing. The 15-minute screening call confirms fit before any introduction to the firm.

Why does Tariff Relief Partners use a $3M import threshold?

The partner law firm runs a 12-step recovery process — ACE registration, entry reconciliation, refund computation, audit preparation, compliance review, and potential litigation at the U.S. Court of International Trade — on a contingency-only basis. For that model to work, the recoverable refund needs to clear roughly $300,000. That correlates with about $3M in annual imports at typical IEEPA blended rates, or $1.5M if China exposure was high. Below that threshold, a flat-fee customs broker is usually a better fit.

Are there any upfront costs?

No. The 15-minute screening call with us is free. The introduction to the partner law firm is free. The firm's initial consultation is free. The actual recovery work is done on a pure contingency basis: the firm's fee is a percentage of duties recovered. If nothing is recovered, you owe nothing. No retainers, no hourly billing, no filing fees passed through to the client.

What's the difference between Section 232, Section 301, and IEEPA tariffs?

Three different statutes, three different fates:

• IEEPA (50 U.S.C. §§ 1701-1708) is what the Supreme Court struck down in February 2026 — the 2025 reciprocal and trafficking tariffs, identifiable under HTSUS Chapter 99 lines 9903.01 and 9903.02. Refundable.
• Section 232 (Trade Expansion Act of 1962) covers steel, aluminum, autos, copper, lumber, and semiconductors. Still in effect. Not refundable through this ruling.
• Section 301 (Trade Act of 1974) is the original China-specific regime from 2018-2019 under HTSUS 9903.88. Still in effect. Not refundable through this ruling.

Many importers paid both IEEPA and Section 232/301 on the same entries — only the IEEPA portion is recoverable. The partner firm's tariff stacking and isolation analysis (step 3 of the 12-step process) separates them entry-by-entry.

What is the Section 122 surcharge?

When the Supreme Court struck down IEEPA tariffs in February 2026, the administration replaced part of the lost rate with a 10-15% temporary import surcharge under Section 122 of the Trade Act of 1974. The Section 122 surcharge took effect February 24, 2026, runs for 150 days unless extended, and is not affected by the IEEPA ruling. Section 122 is forward-looking; the IEEPA refund process is backward-looking. Both can apply to the same business: you may owe Section 122 on current imports while being eligible for an IEEPA refund on 2025 imports.

What is an Importer of Record (IOR)?

The Importer of Record is the legal entity listed on customs filings (Box 26 of CBP Form 7501) as responsible for the imported goods. The IOR pays the duties and is the entity entitled to file for refunds. If you use a customs broker, your business is almost certainly the IOR. If you imported via FedEx, UPS, or DHL only, the carrier is typically the IOR — that is the Tier 2 case, with a different recovery path.

What is liquidation and how do I find my liquidation dates?

Liquidation is when U.S. Customs and Border Protection officially closes the books on an entry by finalizing the duty amount. By default, liquidation happens 314 days after the date of entry, though it can be deemed liquidated earlier or extended by CBP review.

The liquidation date matters because the Section 1514 protest window — your primary refund channel — is exactly 180 days from each entry's liquidation date. Once that window closes on an entry, the refund is permanently lost through the protest path.

To find your liquidation dates: ask your customs broker for an entry summary report covering all 2025 entries, or pull them yourself from the ACE Portal under Reports → Entry Summary History. The partner firm handles this lookup as part of the recovery process — you don't have to compile it manually before the screening call.

What documents do I need to gather?

For the 15-minute screening call: nothing formal. Rough numbers are enough — approximate annual 2025 import volume, top three countries of origin, your customs broker's name, and a sense of whether anyone has filed a refund claim on your behalf.

For the firm's intake (after screening, if you qualify): entry summaries (Form CF-7501) for 2025 entries, customs broker contact, ACE Portal credentials (or the broker's), and an approximate breakdown of imports by country and HTS code. The firm pulls and reconciles the actual ACE data once you engage.

What if I imported via FedEx, UPS, or DHL?

This is the Tier 2 case. When goods arrive via international parcel carrier, the carrier is typically listed as the Importer of Record on the customs filing — not your business. Your business absorbed the tariff cost via carrier surcharges or invoice line items, but does not appear on customs paperwork.

Refund recovery for Tier 2 importers is legally distinct from Tier 1 and the framework is still developing. The partner firm is actively building the strategy. If your imports came primarily through carriers and you have invoices showing tariff pass-through, flag it on the screening call. Tier 2 candidates are tracked, and we reach out when the recovery path is clear.

What if my customs broker has already filed a protest?

Worth understanding what specifically. Customs brokers can pull entry data and file basic Section 1514 protests on simple grounds, but the IEEPA refund process involves multiple components most brokers don't handle: compliance review, audit preparation, statutory interest calculation, refund-offset defense, and (for entries past the 180-day protest window) Court of International Trade litigation under 28 U.S.C. § 1581(i).

If your broker filed protests on some entries but not all, the firm can review the unfiled entries. If your broker filed comprehensive recovery work and did it well, you may not need our service — be direct on the screening call.

Can I file the refund myself without a law firm?

Technically yes — you can file a Section 1514 protest yourself if you are the Importer of Record. Practically, the procedural rules under 19 U.S.C. § 1514, the ACE/CAPE process, and (for older entries) the Court of International Trade have specific requirements: protest content, classification, claim grounds, supporting documentation, deadline calculations.

A misformatted protest gets denied. A missed liquidation deadline forfeits the entry permanently. For importers with significant exposure, having legal counsel managing the full process — including refund-offset defense if the government tries to apply your refund to new Section 122 or 301 liabilities — is typically worth the contingency fee. Importers with under $1M in IEEPA exposure are often better served by a flat-fee customs broker.

How long does an IEEPA refund take to process?

It depends on the filing path:

• Section 1514 protest: CBP typically issues a decision within 60-180 days of filing; if granted, the reliquidation and ACH refund follow within 30 days under 19 U.S.C. § 1505(b).
• ACE/CAPE submission (once generally live): CBP has informally indicated 60-90 days from acceptance.
• Court of International Trade action: six months to two years depending on whether the case is consolidated with lead cases or proceeds individually.

Refunds include statutory interest under 19 U.S.C. § 1505(b) and 26 U.S.C. § 6621 (currently ~6-8% annualized), which adds meaningfully to the recovery on older entries.

What if CBP audits my refund claim?

That concern actually makes the case for working with a law firm rather than against it. CBP scrutinizes every refund submission for compliance — it's routine, not a sign of trouble. The partner firm builds an audit-ready file as step 5 of its 12-step process and runs a compliance and risk assessment as step 6, specifically to surface anything in the underlying entry data that could cause a problem before filing.

If a question comes up post-filing, the firm represents you through the response — including step 12: defending against any government attempt to offset your IEEPA refund against new Section 122 or 301 liabilities.